Companies with supply chains stretching into China and Xinjiang are facing a mountain of compliance challenges.  Over the summer, the Biden Administration has taken numerous aggressive steps to pressure China to address human rights violations in the Chinese province of Xinjiang focusing on the repression of more than a million Uyghurs in that region. Those companies that maintain  supply chains anywhere in Xinjiang have to...

We often discuss the importance of a “Speak Up” culture.  We encourage employees to report their concerns, we emphasize the important of such reporting to the life of an organization. Chief Compliance Officers are a key messenger to spread the message of speaking up.  But what happens when the CCO hesitates or even fails to speak up?  After we all take a little truth serum,...

In two separate enforcement actions, OFAC announced settlements with Alfa Laval Middle East Ltd., a Dubai, UAE company (AL Middle East), and Alfa Laval, Inc., a Virginia-based company (AL US) for violations of OFAC’s Iran Sanctions Program. AL US enlisted its then subsidiary (now operating unit), Alfa Laval Tank, Inc, based in Exton, Pennsylvania (AL Tank), to participate in the scheme.  The Alfa Laval enforcement...

We all know (and repeat every day) that corporate cultures reflect social trends and pressures.  Companies face extraordinary political and social pressures, and this translates into its corporate workforce. Without being overly dramatic, we are witnessing a fundamental social decay in belief in our institutions.  This is not a recent phenomenon – it has accelerated over the last twenty years, and interestingly, has fluctuated over...

“Never doubt that a small group of thoughtful, committed, citizens can change the world. Indeed, it is the only thing that ever has.”― Margaret Mead Let’s start with a basic premise – change is a good thing (or the cynics insist, change may be a good thing).  But most people do not like change. Most people find change threatening, so they would rather know the devil...

Everyone is now on the culture bandwagon.  For those of us pushing the issue over the last decade, welcome aboard to everyone.  But once you join, the work is only beginning. Recent converts are embracing “culture assessments” as the new indicator of enlightenment.  That is a terrific development.  But there is more work to do. To reset the stage, we start with the basic proposition...

The following scenario is disturbing and occurs all too often – a company receives a hotline report of misconduct occurring in its operations in a foreign country, India, for example.  The company launches an internal investigation of the matter and substantiates the allegation.  Financial misconduct occurred, discipline is imposed, two employees are fired and minor adjustments are made to India’s operations.  End of story, case...

Payoneer, Inc., an online money transmitter and prepaid access company, agreed to pay $1.4 million to OFAC to settle violations of multiple sanctions programs.  In an ironic twist, Payoneer, which often touts its comprehensive sanctions and anti-money laundering compliance programs to its business customers, had to acknowledge 2,260 apparent violations of OFAC sanctions. Payoneer is a well-known money service business (MSB) and acknowledged that it...

A corporate scandal does not occur overnight. (Thank you Bob Dylan). A CEO does not begin the day telling him or herself that today is the day to begin the Ponzi scheme or complex fraud.  It is hard to imagine but corporate scandals grow from itsy-bitsy steps to bigger risks, and eventually to the full corporate embrace. (Thank you Three Stooges, “Slowly I Turned”).  Along...

While billionaires continue to trumpet their excess and competitive desires to fly into space, they may want to take a look around before launching themselves on the next rocket to the edge of space for a ten-minute flight. John Glenn’s first manned flight carried much greater import and influence over the world’s imagination. Corporate leaders need to address the world’s challenges – the pandemic, climate...